Free Motion for Extension of Time to File Answer - District Court of Federal Claims - federal

Case 1:06-cv-00306-MCW

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Filed 10/12/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TERESA KIM LANGE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-306C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 32 calendar days, to and including November 13, 2006, within which to file its response to plaintiff's complaint in this case. Defendant's response currently is due to be filed on October 12, 2006. This is defendant's second request for an enlargement of Counsel for defendant has contacted

time for this purpose.

counsel for plaintiff regarding this motion, and he has stated that plaintiff does not oppose this motion. The additional time is necessary because counsel for defendant has not yet received all of the agency's comments regarding plaintiff's complaint. We rely upon agency counsel to

prepare a litigation report concerning the case, pursuant to 28 U.S.C. § 520, so that we may properly respond to actions filed against the United States. Although undersigned counsel for

defendant has received documents from the agency, she expects to receive additional information from the agency within the next few weeks. This information will allow counsel for defendant to Thus, the

complete defendant's response to the complaint.

Case 1:06-cv-00306-MCW

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additional time is necessary within which to receive necessary information from the agency, and complete and file our response to plaintiff's complaint. For the foregoing reason, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 Attorneys for Defendant OCTOBER 12, 2006

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Case 1:06-cv-00306-MCW

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 12th day of October, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" was filed electronically. I understand that

notice of this filing will be sent to all parties by operation of the Court's electronic filing system, and that the parties may access this filing through the Court's system. /s/ Lauren S. Moore